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#1887711 - 01/16/14 08:43 PM BSA at Community Bank
banjo Offline
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Joined: Feb 2005
Posts: 294
For those small community banks out there, I was wondering if you would share whether you have a BSA Officer and Compliance Officer, or if you only have a Compliance Officer that handles BSA and all the other regulations.

For those whose Compliance Officer handles BSA alone, what percent of your time is spent on BSA?

If you could, please include your bank's asset size and number of branches.

Thank you.

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#1887743 - 01/16/14 09:17 PM Re: BSA at Community Bank banjo
osucpa Offline
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For you need to describe your bank.

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#1887809 - 01/16/14 10:52 PM Re: BSA at Community Bank osucpa
banjo Offline
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Posts: 294
$270 million and 7 branches.

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#1887920 - 01/17/14 02:40 PM Re: BSA at Community Bank banjo
BSA Smitten Offline
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Posts: 41
Great Lakes
$200M with 3 branches soon to be 4, BSA Officer and Compliance officer are 2 separate positions within our FI. Both myself and the Compliance Officer each have 2 assistants and we also have a Security Officer.
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#1887925 - 01/17/14 02:46 PM Re: BSA at Community Bank banjo
JWills, CRCM Offline
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JWills, CRCM
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The Mitten State
$232 M with 7 branches, 2 supermarket branches, 1 drive thru branch, and one operations building. I am the Compliance Officer/CRA Officer and we have a separate BSA Officer. We have no assistants. I am also responsible for HMDA and loan denials. We also have a separate Security Officer.

I feel overwhelmed quite frequently and senior management inquired yesterday if I needed an assistant, at least part time. I am thinking it may be a good idea.
Last edited by JWills; 01/17/14 03:51 PM. Reason: missing info
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#1887952 - 01/17/14 03:16 PM Re: BSA at Community Bank banjo
Matt_B Offline
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Matt_B
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A CU, Where Regs Don't Apply
We were $250 million or so when they created my position (compliance officer), $300 or so now. I'm compliance and BSA, spend probably 25-30% of my time on BSA. 5 branches.
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#1887974 - 01/17/14 03:48 PM Re: BSA at Community Bank banjo
Lilly C Offline
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Lilly C
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Sunny Florida
$100 in Assets. Two branches. I'm the BSA, Deposit/Loan Compliance and Security Officer. no assistants.

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#1888000 - 01/17/14 04:24 PM Re: BSA at Community Bank banjo
BSA_Jay Offline
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BSA_Jay
Joined: Mar 2010
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New York
760 Million in assets, 13 branches, Compliance Officer, BSA Officer (myself), AML Investigator, OFAC OFficer, BSA Representative.

The compliance officer has stepped away from BSA to focus more on lending compliance though
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#1888044 - 01/17/14 05:24 PM Re: BSA at Community Bank banjo
CrashDavis Offline
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$142 Million in assets. Three branches. I am Director of Compliance Services. I do audits and compliance. I did do BSA because bank had issues when I started. Regulators said there needs to be separation in compliance and BSA. I have an assistant that does all BSA. I just supervise and review.

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#1888052 - 01/17/14 05:40 PM Re: BSA at Community Bank CrashDavis
BSA_Jay Offline
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BSA_Jay
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New York
Originally Posted By: CrashDavis
Regulators said there needs to be separation in compliance and BSA.


And that's the direction that it seems to be heading in.

Even though the BSA exam technically falls under Compliance, they want to see that there is accountability from a BSA Officer.
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Move along there's nothing to see here.

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#1888053 - 01/17/14 05:44 PM Re: BSA at Community Bank banjo
Beachbum, CRCM Offline
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Joined: Dec 2006
Posts: 485
Knee Deep in Regs
$280 mill, I am BSA/AML, compliance, CRA- no assistance. Amount of time spent on BSA/OFAC/ECDD is about 50%. We do not exempt for CTRs and I am the central filer, about 50 each week.
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#1888068 - 01/17/14 05:56 PM Re: BSA at Community Bank BSA_Jay
JWills, CRCM Offline
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JWills, CRCM
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The Mitten State
Originally Posted By: BSA_Jay
Originally Posted By: CrashDavis
Regulators said there needs to be separation in compliance and BSA.


And that's the direction that it seems to be heading in.

Even though the BSA exam technically falls under Compliance, they want to see that there is accountability from a BSA Officer.


Last year we had a Safety and Soundness Exam and they included BSA in that. This year we wiil have our Compliance Exam. Boy, am I ever excited about that.
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#1888132 - 01/17/14 06:52 PM Re: BSA at Community Bank banjo
Sherlocked Offline
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Posts: 82
221B Baker St.
$100 million 3 branches separate Compliance & BSA Officer.
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#1888147 - 01/17/14 07:05 PM Re: BSA at Community Bank banjo
rlcarey Online
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Joined: Jul 2001
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Galveston, TX
You know, there is something like this that appears and runs on and on about every three months. This results in nothing more that a bunch of apples and oranges comparisons and is a worthless and futile exercise.

Nobody knows specifically what any title is responsibly for and nobody know how one bank's risk profile compares to the other bank. Asset size is meaningless.

Save your fingers and give it a rest. If you want this information, do a search. There are a least a hundred such threads over the last eight years on this subject.

The best thing is to call a bank within your peer group and have a conversation so you can compare meaningful information.
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#1888154 - 01/17/14 07:18 PM Re: BSA at Community Bank banjo
RockChucker, CAMS Offline
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The Country
Party pooper! smile
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#1888157 - 01/17/14 07:25 PM Re: BSA at Community Bank rlcarey
banjo Offline
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Joined: Feb 2005
Posts: 294
I was unable to find all those threads, which was the reason I asked the question.

Thanks to all those who responded, as I did find that information useful.

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#1888613 - 01/21/14 05:34 PM Re: BSA at Community Bank BSA_Jay
WonderWoman Offline
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gone fishin'
Originally Posted By: BSA_Jay
Even though the BSA exam technically falls under Compliance


For 10 years my BSA Exams have always fallen under Safety & Soundness. I'm always seperate from Compliance.

We're $950M 4 branches. Our Risk Dept. consists of 1 CO w/2 assistants, I'm BSA with 2 assistants, and one Internal Auditor.

As Randy suggested - these numbers are hard to gauge. I may have 2 assistants - but what is my risk profile? do I have any BSA issues?

I would find comparable institutions in your area & really dig into similarities. If a small bank has a sophisticated foreign customer base, their BSA needs will be completely different than a larger bank with a vanilla profile. In NorCal we (BSA Officers) created a roundtable to discuss these very things. It's been very helpful.
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